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ed States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adrian& Ross, Lesley Groff, or Nadia Mareinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office,
rs of Epstein, including but not limited to Sarah Kellen, Adrian& Ross, Lesley Groff, or Nadia Mareinkova
t; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision. Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOG), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants
f 101 claims, and these proceedings must therefore be dismissed for lack of subject matter jurisdiction.' See, e.g., Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants
f 101 claims, and these proceedings must therefore be dismissed for lack of subject matter jurisdiction.' See, e.g., Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
B AD Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. . 91 c. C AMENDED COMPLAINT 61
f 101 claims, and these proceedings must therefore be dismissed for lack of subject matter jurisdiction.' See, e.g., Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81, 185 (2000); Florida Wildlife Federation, Inc. v. South Florida Water Management Dist., 647 F.3d 1296, 1302 (11th
Entities connected to both Sarah Kellen and Laidlaw Environmental Services

Jeffrey Epstein
PERSONJane Doe
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONMichael J. Pike
PERSON
George W. Bush
PERSON
Salt Lake City
LOCATIONLeon Black
PERSON
A. Marie Villafana
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON
Scarlett Johansson
PERSONRobert D. Critton
PERSON
Donald Trump
PERSON